Privacy Policy of Instituto Devolver

This Privacy Policy of Instituto Devolver (“Privacy Policy”) contains the general conditions applicable to the treatment of personal data collected by Instituto Devolver Associação Sem Fins Lucrativos, with headquarters in the City of Sao Paulo, State of Sao Paulo, at Rua Campo Verde, No. 105 – House 7, ZIP 01456-010, enrolled at the CNPJ under No. 31.785.936/0001-07 (hereby referred simply as “Instituto Devolver”), through the site “” (“Site”).
This Privacy Policy is destined to rule the treatment of personal data obtained from the Donors through the Site and, due to its publicity, it is not compatible with the allegation of unawareness from any Donor. This Privacy Policy is available at the bottom of the Site's main page under the “Privacy Policy” link for verification by any Donor at any time, regardless of prior registration on the Site. Should you have any question about this Privacy Policy, please contact [email protected] .

Summary of Personal Data Processing by the Instituto Devolver

Controller: Instituto Devolver Associação Sem Fins Lucrativos, CNPJ 31.785.936/0001-07
Purpose: To enable donations and sending information, actions and results of the Instituto Devolver.
Legitimacy: Execution and availability of Site features
Sharing: Data may be transferred to third parties as provided in this Privacy Policy.
Rights: The Donor may exercise its rights of access, rectification, deletion, limitation, opposition and portability as described in this Privacy Policy.


Specific Purpose of the treatment: We collect and use Personal Data primarily for making financial donations on the site and for submitting information, actions and results about the Instituto Devolver, as well as for secondary purposes described in clauses 2.3 and 2.4.
Form and Duration of Treatment: We treat Personal Data collected directly from the Donor. We take reasonable and appropriate physical, technical and administrative measures to safeguard the information we collect and treat. We maintain your information for as long as necessary or relevant to the purpose described above and as permitted by applicable law.
Identification of the controller: Instituto Devolver – Associação Sem Fins Lucrativos, headquartered in the City of São Paulo, State of Sao Paulo, at Rua Campo Verde, 61 – 1st. Floor, ZIP Code 01456-010, registered with the CNPJ under No. 31.785 936 / 0001-07.
Controller contact information: To exercise your rights, or if you have questions or concerns about our Privacy Policy, our collection and use of your Personal Data, or a possible violation of privacy laws, you may contact the Instituto Devolver at: [email protected].
Information on Shared Data Usage and Purpose: We may share your Personal Data with our hosting provider ( and with the fundraising software we use: GetNet (, Donor Box ( and PayPal (
Responsibilities of treatment agents: The Instituto Devolver will only authorize third parties to process your Personal Data subject to the appropriate contractual obligations in force. If we are unable to resolve your issues or if you believe that data protection rules have been violated, you have the right to take legal and administrative action.
Holder Rights: You may at any time request the Instituto Devolver: (i) confirmation that your Personal Data is being processed; (ii) access to your Personal Data; (iii) corrections to incomplete, inaccurate or outdated data; (iv) anonymization, blocking or deletion of unnecessary, excessive or treated data in breach of the law; (v) portability of Personal Data to another service provider as long as it does not affect our industrial and trade secrets; (v) deletion of Personal Data processed with your consent to the extent permitted by law; (vi) information about the entities to which your Personal Data has been shared; (viii) information about the possibility of not providing consent and the consequences of the refusal (in some cases the Instituto Devolver will not be able to provide certain services or answer questions you may have); and (ix) revocation of consent.


1.1. For the purposes of this Privacy Policy:
i. “Personal Data” means information that enables the identification, directly or indirectly, of natural persons;
ii. “Sensitive Personal Data” means Personal Data about racial or ethnic origin, religious belief, political opinion, union affiliation or religious, philosophical or political organization, health or sex life data, genetic or biometric data, when bound to a natural person;
iii. “Processing of Personal Data” means any operation performed on Personal Data, such as the collection, production, receipt, classification, use, access, reproduction, transmission, processing, archiving, storage, deletion, evaluation or control of information, modification , communication, transfer, diffusion or extraction; and
iv. “Data Protection Laws” means all legislation applicable to the Processing of Personal Data, which includes, without limitation, Law No. 13,709 / 2018.


2.1. We process the following Donor data for Site-related purposes, which may or may not constitute Personal Data:
i. Identification data: full name, email, telephone and social security number.
ii. Financial Data: Any credit card information collected by the Instituto Devolver.
iii. Access data: Site access browser; Internet Protocol (IP) Address; logs (date and time of access); the location of the Donor; Donor actions on the Site; mobile device model and operating system used to access the Site; connection provider; interactions between the Instituto Devolver and the Donor, via the Website, by email and / or telephone; and other automatically collected data, such as those obtained through cookies (as provided in item 6 of this Privacy Policy).
2.2. The Instituto Devolver does not treat Sensitive Personal Data. We treat your Personal Data to manage your relationship with the Instituto Devolver for the purposes of performing the Site functionality, which includes the following purposes:
i. To enable donations made through the Site;
ii. To respond to your queries and fulfill your requests;
iii. To confirm or correct the information we have about you;
iv. To submit information, actions and results of the Instituto Devolver;
v. To protect the Site against errors, fraud or any other electronic crime;
vi. To allow your account to stay connected to your mobile / computer even after use, save information about you, such as credit card details and name;
vii. Contact the Donor at a telephone number and / or email address provided. We may contact you in person, by voice message, through automatic dialing equipment, by text messaging (SMS), by email, or by any other means of communication your device may receive, under the terms of law and for commercial purposes relating to the Site;
viii. To share data as provided in Clause 4.
2.3. In addition, the Personal Data you provide may also be used in such manner as we deem necessary or appropriate: (a) for the regular exercise of rights in judicial, administrative and arbitral proceedings; (b) to comply with a legal or regulatory obligation; and (c) in other ways permitted by law.
2.4. In addition, the Privacy Policy does not apply to any third party applications, products, services, websites or social media features that may be offered or accessed through the Site. Access to these links will cause you to leave the Site and may result in the collection or sharing of information about you by third parties. We do not control, endorse, or make any representations about these third party sites or their privacy practices, which may differ from ours. We recommend that you review the privacy policy of any site you interact with before allowing the collection and use of your Personal Data.
2.5. If you send us Personal Data regarding other individuals, you represent that you have the competence to do so and you have obtained the necessary consent to authorize the use of such information under this Privacy Policy.


3.1. You are not required to share the Personal Data we request, however, if you choose not to share it, in some cases we will not be able to provide you with all services provided by the Site or be able to respond effectively to inquiries you may make.


4.1. The Instituto Devolver may share your Personal Data:
With service providers or partners to manage or support certain aspects of our business operations on our behalf, such as hosting and data storage service providers, fraud management, donor support, sales on our behalf, order fulfillment, customization content, advertising and marketing activities (including digital and personalized advertising), IT services and donation capture software, including the hosting server ( and the fundraising tool resources provided by Donor Box (; and With third parties, in the event of any reorganization, merger, sale, joint venture, assignment, transfer or transfer of all or part of our institute.


5.1. Donations made through Getnet and PayPal software have their payments processed with Getnet and PayPal. Getnet and PayPal is a Payment Institution fully independent of the Instituto Devolver. 5.2. Any questions about the services provided by Getnet and PayPal should be resolved with Getnet and PayPal through their Terms of Use and Privacy Policy.
5.3. If the Donor has any questions involving a donation made through the software provided by Getnet and PayPal, the Donor should contact Getnet and PayPal directly.


6.1. The Site is hosted on the server (, to which Donor name, email, phone, and social security number are transferred. We also use the Donor Box fundraising tool ( to which Donor name and email are transferred. Such data may be transferred to servers of such companies located in other countries, including the United States and Chile.
7. AUTOMATIC PERSONAL DATA COLLECTION FORM 7.1. In accordance with this Privacy Policy, we and our third party service providers may collect your Personal Data in a variety of ways, including but not limited to:
7.2. Via browser or device: Some information is collected by most browsers or automatically through Internet access devices, such as computer type, screen resolution, operating system name and version, device model and manufacturer. , language, type and version of the web browser you are using. We may use this information to ensure that the Site functions properly.
7.3. Use of Cookies: Information about your use of the Site may be collected by third parties through cookies. Cookies are information stored directly on the computer you are using. Cookies allow the collection of information such as browser type, time spent on websites, pages visited, language preferences, and other anonymous traffic data. We and our service providers use information for security protection, to facilitate navigation, to display information more efficiently, and to personalize your experience using the Site, as well as for online tracking. We also collect statistical information about your use of the Site to continually improve our design and functionality, to understand how the Site is accessed, and to assist you in resolving Site-related issues.
7.4. Use of Google Analytics: The Google Analytics tool, a web analytics service provided by Google, is used to understand Donor's use of the Site. Google Analytics collects information such as how often Donor accesses the Site and what other web pages are used by Donor. Google uses the data it collects to track and review Site usage, prepare reports on its activities, and share it with other Google services itself. Google may use the data collected on or through the Site to contextualize and customize the ads in its own ad network. Google's ability to use and share information Google Analytics collects about your visits to and use of the Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Google offers a disabling mechanism available here
7.5. Google Tag Manager. The Google Tag Manager tool is a cookie service provided by Google and is used to allow us to recognize your device on your next access. Google's ability to use and share information collected by Google Tag Manager about your visits to and use of the Site is restricted by the Google Tag Manager Privacy Policy.
7.6. If you do not want your information collected through cookies, there is a simple procedure in most browsers that allows cookies to be automatically rejected, or offers the option to accept or reject the transfer of a specific cookie (or cookies) ( s) from a particular site for your computer. However, this may cause inconvenience to use the Site.
7.7. The settings you choose may affect your browsing experience and the functionality of certain features that require the use of cookies. In this regard, we disclaim any liability for the consequences resulting from the limited operation of our Site caused by disabling cookies on your device (inability to set or read a cookie).


8.1. You may at any time request the Instituto Devolver: (i) confirmation that your Personal Data is being processed; (ii) access to your Personal Data; (iii) corrections to incomplete, inaccurate or outdated data; (iv) anonymization, blocking or deletion of unnecessary, excessive or treated data in breach of the law; (v) portability of Personal Data to another service provider as long as it does not affect our industrial and trade secrets; (v) deletion of Personal Data processed with your consent to the extent permitted by law; (vi) information about the entities to which your Personal Data has been shared; (viii) information about the possibility of not giving consent and about the consequences of the refusal (as per Clause 3 above); and (ix) revocation of consent. Your requests will be handled with special care so that we can ensure the effectiveness of your rights. You may be required to provide proof of your identity in order to ensure that the sharing of Personal Data is only by its owner.
8.2. You should be aware that in certain cases (eg due to legal requirements) your request may not be immediately fulfilled and the Instituto Devolver may not be able to fulfill your request because of legal obligations.


9.1. We seek to adopt the technical and organizational measures provided for by the Data Protection Laws appropriate for the protection of Personal Data at our institute.
9.2. No data transmission or storage system is guaranteed to be 100% secure. In any case, we always strive to prevent leaks from occurring by adopting a high level of protection certified by specialized safety companies.
9.3. All identifiable data is stored in encrypted form. The information is protected with Secure Sockets Layer (SSL) technology so that Donor data remains confidential and not transmitted or accessed by unauthorized third parties.
9.4. If you have reason to believe that your interaction with us is no longer secure (for example, if you believe the security of your data has been compromised), please inform us immediately, as per Clause 11 below.


10.1. If the Donor is a minor, we ask your legal guardian to consent to this Privacy Policy.


11.1. The Instituto Devolver is entitled to return the right to change this Privacy Policy at any time without notice to Donors, so it is the duty of the Donor to be aware of possible updates to such documents, which will be immediately made available on the channels usually used by the Instituto Devolver, and modifications will be effective from the date of publication. In the event of any change to this Privacy Policy related to (i) the specific purpose of processing Personal Data; (ii) the form and duration of the processing of Personal Data, subject to the Instituto Devolver's trade and industrial secrets; (iii) the identification of the controller of the Personal Data; and / or (iv) information about the controller's shared use of Personal Data and the purpose, we will inform the Donor in a prominent manner, either through the contact information we have in our database or through notification on the Site.
11.2. Please note that Instituto Devolver is committed not to treat your Personal Data in a manner inconsistent with the purposes described above unless otherwise required by law or court order.
11.3. Your use of the Site following the changes means that you have accepted the current version of the Privacy Policy. If, after reading the revised version, you do not agree to its terms, please terminate access to the Site.


12.1. If you wish to exercise any of the rights under this Privacy Policy and / or Data Protection Laws, or if you have any questions regarding the processing of your Personal Data, please contact us at [email protected] .


13.1. This Privacy Policy will be governed by and construed in accordance with the laws of the Federative Republic of Brazil.
13.2. The parties elect the District Court of São Paulo, State of São Paulo, as the sole competent to settle any dispute resulting from this Privacy Policy.
13.3. The Site is controlled and operated by the Instituto Devolver from its offices in Brazil and intended for the public located in the Brazilian territory. We do not warrant that materials on the Site are appropriate or available for use in locations outside of Brazil, or that access to such content is lawful in all territories. If you access the Site from locations outside of Brazil, you will be responsible for compliance with all local laws and may not use the Site or export materials from the Site when this constitutes a violation of applicable law.

*Last updated: August 19, 2019.